As I detailed in the previous installment of this series, the deadlines federal agencies face to manage all of their records electronically create a sense of urgency. Unfortunately, history has shown that agencies don’t always choose the best course of action as they try to comply.
The seemingly most obvious path toward electronic records management is to procure and implement records management software. However, managing records, especially across large agencies, is not as simple as that. Federal agencies have done that repeatedly over the past couple of decades with, at best, mixed results.
Those agencies that have been successful took a more measured approach. They didn’t try to address every record challenge at the same time. Instead, they analyzed their greatest needs and created a records strategy. This led many of them to success, while greatly reducing the risk of having to restart the process every few years.
Read the federal requirements at the National Archives.
Assess What You Have
The first step in any journey is understanding the current landscape. Therefore, most agencies have performed records inventories. What is often missing is an assessment of the systems managing those records. That assessment is necessary for a strategic approach, but even that is incomplete without understanding the effectiveness of those systems, in both managing records and supporting the mission.
- Are you relying on manual processes to capture records?
- Are there adequate controls that protect records while not restricting operations?
- Can agency personnel readily find and access records when needed?
- Most importantly, do your systems meet the National Archives and Records Administration’s Universal Electronic Records Management (UERM) requirements? If not, then the agency’s records may be at risk.
Identify Your Risk Areas
Agencies need to identify those records most at risk within their organization and prioritize the proper management of those records.
Most agencies have several categories of records that they are not managing in a manner compliant with RM policies. While having finance place records into a structured Microsoft 365 site may not be ideal, it works better than storing their official records in email. CGI’s experience shows that agencies manage records better when the records are part of a structured process—even if the storage location is not a true records repository.
The records most often at risk are those tied to paper processes. Paper gets lost, and is non-compliant with Office of Management and Budget Memorandum M-19-21. Electronic permanent records are also at risk. Agencies effectively manage permanent records for the first few years of life, but long-term management is rarely effective if the agency doesn’t properly capture, categorize, and store permanent records in an electronic records repository.
Putting Together a Strategic Plan
Working alongside key stakeholders, putting together a prioritized list of record initiatives is an important first step for agencies. The first items often include efforts to clarify policies and processes that support the electronic record. The resulting records management roadmap is a living document that an agency can use to best focus and plan their records management efforts.
The 18-month deadline extension NARA recently implemented is not enough time for agencies to do everything they need to do to achieve M-19-21 compliance, if they are not already far along their records strategy roadmap. However, it is enough time to ensure that they are on the right path and will not have to start over later. It is enough time to begin executing against a solid records management plan and roadmap. That might be enough to persuade NARA to allow individual agencies more time.
If you need help getting started or determining if you are on the right path, contact us today.